Did the Plaintiff retain an ownership interest in the excised cells and matter such that he may prosecute the Defendants for conversion? Northwest Univ Law Rev. Rptr. Bibliographic Citation. P was a patient at UCLA Medical Center. This is not a forum for general discussion of the article's subject. Plaintiff Deborah Moore appealed a judgment entered in favor of defendant The Regents of the University of California. Held. Thank you and the best of luck to you on your LSAT exam. Your Study Buddy will automatically renew until cancelled. Unlock your Study Buddy for the 14 day, no risk, unlimited trial. I use a nearly full-text version of Moore v. Regents of the University of California, as the first case in Property and find it to be a very useful tool for introducing not only a number of key property law concepts but also a number of concepts (not all of which directly relate to property) that are revisited throughout the curriculum, as well as contrasting the more dynamic body … 1990). Rptr. 3 See Moore v. Regents of the University of California (1988) 249 Cal. First, no reported judicial decision supports Moore's claim, either directly or by close analogy. If you do not cancel your Study Buddy subscription, within the 14 day trial, your card will be charged for your subscription. JOHN MOORE, Plaintiff and Appellant, v. THE REGENTS OF THE UNIVERSITY OF CALIFORNIA et al., Defendants and Repondents. There are many cases in which the law forbids the exercise of certain rights over certain forms of property. D did not disclose his research interests to P even though he knew of the research and commercial benefits he might receive from retaining P's cells while he was still treating P. D kept having P come back to UCLA from Seattle and kept withdrawing additional samples of body fluids and tissues. After they removed his spleen doctors (Defendants) found out his cells were unique and had a great commercial value. This Comment examines and rejects the property law approach to this issue. It is not like a name or a face, since they are not unique to Moore. Tissue was removed from Moore (Plaintiff) by several doctors who planned to conduct research with the hope of achieving financial gain. LEXIS 2858, 15 U.S.P.Q.2D (BNA) 1753, 793 P.2d 479, 16 A.L.R.5th 903 (Cal. California. 3d 120; 271 Cal. Creator. There are not property rights for ethical, religious etc reasons The court feared that because conversion is a strict liability tort, it may open up too many law suits -- Download Moore v Regents of University of California (1990) 51 Cal 3d 120 as PDF -- 1990), Supreme Court of California, case facts, key issues, and holdings and reasonings online today. Regents of the University of California • Moore went to UCLA Med Center for treatment after learning he had hairy cell leukemia. Court of Appeal, Second District, Division 4. Moore v. Regents of the University of California. Your Study Buddy will automatically renew until cancelled. Tissue was removed from Moore (Plaintiff) by several doctors who planned to conduct research with the hope of achieving financial gain. 1988 Jul 21;249:494-540. questions in the case of Moore v. Regents of the University of California.' 1992 Winter;86(2):453-96. Unlock your Study Buddy for the 14 day, no risk, unlimited use trial. To impose such a duty would affect medical research and implicate lots of policy concerns. This Comment examines and rejects the property law approach to this issue. Jul 9, 1990.] Start studying Property Pt.1 - Moore v Regents of the University of California. However, conversion is a strict liability tort which subjects innocent third parties to liability for acts which may not be under their direction and control. 5 See ibid at 479 6 See ibid at 479 7 See Gold, Richard. A tort of conversion occurs when personal property of one person is interfered with by another with regard to possessory or ownership interests. Second, California statutory law drastically limits any continuing interest of a patient in excised cells. (Superior Court of Los Angeles County, No. Moore filed a thirteen-count lawsuit. Moore v. The Regents of University of California Supreme Ct of CA- 1990 Facts. P's claim of ownership is also invalid because CA statutory law drastically limits a patient's control over excised cells for public health reasons. Moore v Regents of the University of California Moore (Plaintiff) sought treatment for hairy-cell leukemia at Regents (Defendants). Plaintiff Moore was a cancer patient at U.C.L.A. Moore v. Regents of the University of California. Brief Fact Summary. JOHN MOORE, Plaintiff and Appellant, v. THE REGENTS OF THE UNIVERSITY OF CALIFORNIA et al., Defendants and Repondents. Abstract. This is the talk page for discussing improvements to the Moore v. Regents of the University of California article. It is inequitable and immoral that P should not be compensated when without Moore's cells the profitable cell line would have never been created. MOORE V. REGENTS OF THE UNIVERSITY OF CALIFORNIA In Moore v. Regents of the University of CaliforniaJ the California Court of Appeals was one of the few courts in recent history to face the issue of whether the sale of a human's body part should be permitted. Jul 9, 1990.] Subsequently, a cell line was developed from Moore's tissues that offered enormous therapeutic value. The legislative intent was, according to the Court, to limit the patient’s ownership of any material excised in the course of medical treatment. 146; 793 P.2d 479) was a landmark Supreme Court of California decision filed on July 9, 1990 which dealt with the issue of property rights in one's own body parts.John Moore underwent treatment for hairy cell leukemia at the UCLA Medical Center under the supervision of Dr. David W. Golde. No court has ever upheld conversion liability for this. 146; 793 P.2d 479) was a landmark Supreme Court of California decision filed on July 9, 1990 which dealt with the issue of property rights in one's own body parts. On 9 July 1990, in Moore v. Regents of the University of California, the Supreme Court of California ruled in a four-to-three decision that individuals do not have rights to a share in profits earned from research performed on their bodily materials. The researcher who gets material does not have to be ignorant of limitations on its use, so if he is sure there is consent, there would be no conversion. On 9 July 1990, in Moore v. Regents of the University of California, the Supreme Court of California ruled in a four-to-three decision that individuals do not have rights to a share in profits earned from research performed on their bodily materials. Abstract. Moore sued the university for violation of the Fair Employment and Housing Act and the California Family Rights Act. Learn vocabulary, terms, and more with flashcards, games, and other study tools. edented decision declaring human tissue2 to be property of the person from whom it is removed. Rptr. D put the work in (labor theory), so he got the patent. No. His spleen then was retained for research purposes without his knowledge nor consent. 146, 1990 Cal. 3d 120, 271 Cal. In Moore v. Regents of the University of California,3 the court held that John Moore, a patient at the UCLA Medical Center, had a cognizable action for conversion of … Court discusses disclosure issue- says doctor was required to disclose research interests. If you do not cancel your Study Buddy subscription within the 14 day trial, your card will be charged for your subscription. The superior court sustained all defendants' demurrers to the third amended complaint, and the Court o… As a pre-law student you are automatically registered for the Casebriefs™ LSAT Prep Course. It is the inventive effort that patent law rewards with a patent, not just the discovery of a naturally occurring raw material. . KIE: In 1976, John Moore had his spleen removed in the course of treatment for hairy cell leukemia at the UCLA Medical Center. Plaintiff Deborah Moore appeals from a judgment entered in favor of defendant The Regents of the University of California (Defendant). Rptr. disputes over the ownership of cell lines 338 a. cases prior to moore 338 b. facts and procedural history of moore 339 iv. If, as alleged in this case, P's doctor improperly interfered with P's right to control the use of a body part by wrongfully withholding material information from him before its removal, P may maintain a conversion action. Email Address: You can opt out at any time by clicking the unsubscribe link in our newsletter, If you have not signed up for your Casebriefs Cloud account Click Here, Thank you for registering as a Pre-Law Student with Casebriefs™. Plaintiff did not state a cause of action based on conversion, but may prosecute the case based on theories of breach of fiduciary duty or lack of informed consent. 146; 793 P.2d 479) was a landmark Supreme Court of California decision filed on July 9, 1990 which dealt with the issue of property rights in one's own body parts. Moore v. Regents of the University of California. One illustrative case is Moore v. Regents of the University of California, in which a patient sued his doctor for conversion of his spleen which had been removed for therapeutic purposes. Second, California statutory law drastically limits any continuing interest of a patient in excised cells. Mr. Moore filed suit in 1984 seeking a share of the profits from the drug derived from his spleen. Non-Traditional Objects And Classifications Of Property, 14,000 + case briefs, hundreds of Law Professor developed 'quick' Black Letter Law. The plaintiff in Moore alleged that he had a property interest in his excised spleen and tissue which defendants had used in commercially profitable medical research.4 The California I. U.S. Congress, Office of Technology Assessment (OTA), New Developments in Moore claimed the modified tissue to be his own property and sued to recover deserved profits. Majority says P did not retain ownership interest in his cells after removal. We granted review in this case to determine whether plaintiff has stated a cause of action against his physician and other defendants for using his cells in potentially lucrative medical research without his permission. One illustrative case is Moore v. Regents of the University of California, in which a patient sued his doctor for conversion of his spleen which had been removed for therapeutic purposes. . 146, 793 P.2d 479, 15 U.S.P.Q.2d 1753 (1990) Brief Fact Summary. . Synopsis of Rule of Law. 1 Moore v. Regents, U. California, 793 P.2d 479 (Cal. P was a patient at UCLA Medical Center. The Court noted a California statute which ordered that any materials removed from patients be disposed of in a safe matter. Ms. Schmidt holds a B.A. Dissent. Moore sued Defendant for claims under the Fair Employment and Housing Act (FEHA) (Gov.Code, 1 §§ 12900–12966) and the California Family Rights Act (CFRA) (§§ 12945.1, 12945.2). Copyright (c) 2009 Onelbriefs.com. Moore v. Regents of the University of California. Court of Appeal. Plaintiff Deborah Moore appeals from a judgment entered in favor of defendant The Regents of the University of California (Defendant). In its decision, the Supreme Court of California ruled that cancer patient John L. Moore did not have personal property rights to samples or fluids that his physicians … Moore did not expect to retain possession of his cells following conversion, so he must have an ownership interest in them. Casebriefs is concerned with your security, please complete the following, Traditional Objects And Classifications Of Property, Improving Another's Property By Mistake (Accession), A Brief Look At The Historical Development Of Estates Doctrine, Non-Freehold Estates: Landlord And Tenant, Interests In Land Of Another And In Natural Resources Affecting Another's Land, Introduction To The Traditional Land Use Controls, Easements,Covenants,Servitudes and Related Interests, LSAT Logic Games (June 2007 Practice Exam), LSAT Logical Reasoning I (June 2007 Practice Exam), LSAT Logical Reasoning II (June 2007 Practice Exam), You can opt out at any time by clicking the unsubscribe link in our newsletter, Moore v. Regents of the University of California, 22 Ill.51 Cal.3d 120, 271 Cal.Rptr. Moore v. Regents of the University of California. Golde and UCLA researcher Shirley Quan planned to use Moore’s spleen tissue—which was “o… Third, the subject matters of the Regents' patent -- the patented cell line and the products derived from it -- cannot be Moore's property. 146, 793 P.2d 479, 15 U.S.P.Q.2d 1753 (1990). C513755, Warren H. Deering and John L. Cole, Judges.) He was treated and, unbeknownst to him, his doctor (Golde) established a cell line from Moore's T lymphocytes, got a patent on it, and sold it to make quite a bit of money. In the first case of its kind, the California Supreme Court held in Moore v. Regents of the University of Californiathat individuals do not have an ownership interest in their cells after the cells are removed from their bodies. The trial court granted summary judgment in … D (Doctors) used P's cells to create a cell line and made lots of money off of it. C513755, Warren H. Deering and John L. Cole, Judges.) This case is an example of the cases which arise when new technologies force courts to re-examine historical principles. Moore's complaint states a cause of action for breach of fiduciary duty or lack of informed consent, but not conversion. Written and curated by real attorneys at Quimbee. INTRODUCTION The decision of the California Supreme Court in Moore v Regents of the University of California and ors2 has brought the question of whether the human body and its tissue can, or ought to be considered property, from an era of grave robbers into the hospitals and laboratories of the late twentieth century. Moore v. Regents of the University of California (51 Cal. The Court finds that the cell line is factually and legally distinct from any part of materials removed from Plaintiff’s body. Doctors applied for patents on the cell line and entered into contracts for its commercial exploitation. the technology 335 iii. Subsequently, a cell line was developed from Moore's tissues that offered enormous therapeutic value. John Moore sought treatment from UCLA Medical Center (defendant) for hairy-cell leukemia. videos, thousands of real exam questions, and much more. She is a J. D. candidate at FPLC concentrating in intellectual property law. The doctor later used the spleen to develop a patented and profitable cell-line. Supreme Ct of CA holds that there is a requirement for disclosure of physicians' research interest, but there are no property-related claims. Further, that as the result of the alleged conversion, Plaintiff asserts a right to a portion of any profit resulting from the use of the excised material. questions in the case of Moore v. Regents of the University of California.' The Plaintiff wishes to have a legally recognized right to sell portions of his body for profit, and such a result is immoral. The defendants made a significant amount of money from the cell line. There are not property rights for ethical, religious etc reasons; The court feared that because conversion is a strict liability tort, it may open up too many law suits-- Download Moore v Regents of University of California (1990) 51 Cal 3d 120 as PDF--Save this case In 1986, a Superior Court in Los Angeles refused to accept the case. Moore relies on privacy rights and unwanted publicity. Every Bundle includes the complete text from each of the titles below: PLUS: Hundreds of law school topic-related videos from The Understanding Law Video Lecture Series™: Monthly Subscription ($19 / Month) Annual Subscription ($175 / Year). Moore sued Defendant for claims under the Fair Employment and Housing Act (FEHA) and the California Family Rights Act (CFRA). Filed on July 9, 1990, it dealt with the issue of property rights to one's own cells taken in samples by doctors or researchers. moore v. the regents of the university of california: balancing the need for biotechnology innovation against the right of informed consent by maureen s. dorneyf table of contents i. introduction 334 ii. The patent was held by the Regents of the University of California (Regents) (defendant), and listed as inventors Golde and UCLA researcher Shirley Quan (defendant). KIE: In 1976, John Moore had his spleen removed in the course of treatment for hairy cell leukemia at the UCLA Medical Center. In addition, commercial exploitation is not scientific use, so it shouldn't be covered by the statute permitting scientific use. The trial court dismissed Moore's case because it failed to set forth a proper claim at law. California. Division 4. Moore v. Regents of the University of California (51 Cal. Design by Free CSS Templates. The Court is concerned with the rights of the patient. Moore v. Regents of the University of California: expanded disclosure, limited property rights. Plaintiff Moore was a cancer patient at U.C.L.A. He had hairy-cell leukemia and had to get his spleen removed. On 9 July 1990, inMoore v. Regents of the University of California, the Supreme Court of California ruled in a four-to-three decision that individuals do not have rights to a share in profits earned from research performed on their bodily materials. 4 Moore v Regents of the University of California 793 P. 2d at 481(1990). Court of Appeal, Second District, Division 4. LEXIS 2858, 15 U.S.P.Q.2D (BNA) 1753, 793 P.2d 479, 16 A.L.R.5th 903 (Cal. Please check your email and confirm your registration. in Chemistry from Indiana University of Pennsylvania and has biotechnology research experience. CitationMoore v. Regents of University of California, 51 Cal. Third, the subject matters of the Regents' patent--the patented cell line and the products derived from it-- cannot be Moore's property. The Court notes that historically the tort of conversion arose to settle disputes between losers and finders. The plaintiff in Moore alleged that he had a property interest in his excised spleen and tissue which defendants had used in commercially profitable medical research.4 The California I. U.S. Congress, Office of Technology Assessment (OTA), New Developments in “Owning Our Bodies: An Examination of Property Law and Biotechnology”. All rights reserved. Discussion. 3d 120; 271 Cal. 1. They can be used for research, but if they are not used for research they must be discarded. Lymphokines have the same molecular structure and function in every human being. Filed on July 9, 1990, it dealt with the issue of property rights to one's own cells taken in samples by doctors or researchers. He should have given Moore the choice, but as a property issue the Doc is in the clear. Thus, the Court declined to extend conversion liability in this type of suit. July 9, 1990) Brief Fact Summary. Plaintiff alleges that his physician failed to disclose preexisting research and economic interests in the cells before obtaining consent to the medical procedures by which they were extracted. Put new text under old text. Even if it did include commercial use, it does not follow that P does not have a property right for purposes of conversion. California. Medical Center where his doctor, over a period of several years, removed blood and other bodily fluids from Plaintiff which eventually became a “cell line” and was patented for commercial use, which aggrieved Plaintiff. Moore v. Regents of the University of California was a landmark Supreme Court of California decision. Rptr, at 495. Therefore, application of the law of conversion in this case will not hinder research by restricted access. The disclosure part of the holding upholds the desired policy without infringing on socially useful research. CALIFORNIA REPORTER 249: 494-540. San Diego Law Review. D (Doctors) used P's cells to create a cell line and made lots of money off of it. Patentability has significantly reduced the free access of researchers to new cell lines and their products. FN20. In Moore v. Regents of the University of California,3 the court held that John Moore, a patient at the UCLA Medical Center, had a cognizable action for conversion of his spleen, removed as part of his medi- Second Appellate District. You also agree to abide by our. It is clear under CA la that before a body part is removed it is the patient, rather than his doctor or hospital, who possesses the right to determine the use to which the body part will be  put after removal. However, this is not property law, and a conversion claim must be based on property law. (Superior Court of Los Angeles County, No. To establish  conversion, P must establish actual interference with ownership or right of possession. Concurrence. The patented cell line is factually and legally distinct from the cells taken from Moore's body. Moore v. Regents of the University of California Wests Calif Report. Can there be a property right claim to bodily fluids and tissues that have been removed from the body? address. However, the subject matter of the patent, the cell line, cannot be Moore's property. We don't want to threaten civil liability for medical research for those researchers who have no reason to believe that use of a particular cell sample is against a donor's wishes. CitationMoore v. Regents of University of California, 51 Cal. Citation 22 Ill.51 Cal.3d 120, 271 Cal.Rptr. July 9, 1990) Brief Fact Summary. On conversion issue, Moore argues that he continued to own his cells following their removal from his body, at least for the purpose of directing their use. Next, court addresses whether conversion liability should be extended and answers in the negative. Moore v. Regents of the University of California (51 Cal. Start studying Property Pt.1 - Moore v Regents of the University of California. The argument that this is a decision for the legislature is crap; the whole point of having common law is that it can morph to changing needs. In early September 2010, Moore was … He had hairy-cell leukemia and had to get his spleen removed. Supreme Court of California. MOORE V. REGENTS OF UNIVERSITY OF CALIFORNIA. You have successfully signed up to receive the Casebriefs newsletter. 3 RISK-Issues in Health & Safety 219 [Summer 1992] This makes it difficult to call P's rights property rights. Legislature should make this decision. 3d 120; 271 Cal. Get Moore v. Regents of the University of California, 793 P.2d 479 (Cal. On 9 July 1990, inMoore v. Regents of the University of California, the Supreme Court of California ruled in a four-to-three decision that individuals do not have rights to a share in profits earned from research performed on their bodily materials. 3d 120, 271 Cal. 32: 1203(1990). A link to your Casebriefs™ LSAT Prep Course Workbook will begin to download upon confirmation of your email Property candidate at FPLC. His attending physician, Dr. David Golde, recommended removal of Moore’s spleen for therapeutic purposes. Learn vocabulary, terms, and more with flashcards, games, and other study tools. Moore v. Regents of the University of California was a landmark Supreme Court of California decision. The doctor later used the spleen to develop a patented and profitable cell-line. You also agree to abide by our Terms of Use and our Privacy Policy, and you may cancel at any time. 146, 1990 Cal. Supreme Court of California. Rptr. The court found that the breach of fiduciary duty theory and the lack of informed consent theory were better suited to protect the rights of patients. Medical Center where his doctor, over a period of several years, removed blood and other bodily fluids from Plaintiff which eventually became a “cell line” and was patented for commercial use, which … In this case the Plaintiff argues that the matter taken from his body belonged to him and that he did not authorize the Defendants to use the excised material to profit. That no action based on a theory of conversion may be prosecuted where the subject matter of the allegation are excised cells taken from Plaintiff in the course of a medical treatment; however, that an action may be based on theories of breach of fiduciary duty or lack of informed consent. Moore began working in UCSD's Marketing and Communications Department (the Department) in 2008. There is no property right to bodily fluids that have already been removed from the body. The Plaintiff’s body is unique and based upon ethical and equitable concerns the Plaintiff should have a proprietary interest in the cells and tissue of his body. Issue. 1995. The Court examined Plaintiff’s claim under the existing law and found that no judicial decision could be found to support the claim, that statutory law drastically limits the continuing interest of a patient in excised tissue, and finally that the subject matter of the patent cannot possibly belong to Plaintiff. Objects and Classifications of property, 14,000 + case briefs, hundreds of law Professor developed 'quick ' Black law! Unlock your Study Buddy for the 14 day, no several doctors who planned to use Moore ’ spleen. Cases which arise when new technologies force courts to re-examine historical principles you have successfully up! They are not used for research purposes without his knowledge nor consent disclosure moore v regents of the university of california property physicians ' interest! 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